Environmental Protection Environmental Principles, Assessments … · 2020. 10. 14. · September 2020 REGDOC-2.9.1, Environmental Principles, Assessments and Protection Measures

Environmental Protection

Environmental Principles, Assessments and Protection Measures REGDOC-2.9.1, version 1.2 September 2020

Environmental Protection: Environmental Principles, Assessments and Protection

Measures Regulatory document REGDOC-2.9.1

© Canadian Nuclear Safety Commission (CNSC) 2020

Cat. No. CC172-164/2016E-PDF

ISBN 978-0-660-06255-6

Extracts from this document may be reproduced for individual use without permission provided the

source is fully acknowledged. However, reproduction in whole or in part for purposes of resale or

redistribution requires prior written permission from the CNSC.

Également publié en français sous le titre : Protection de l’environnement : Principes, évaluations

environnementales et mesures de protection de l’environnement

Document availability This document can be viewed on the CNSC website. To request a copy of the document in English or

French, please contact:

Canadian Nuclear Safety Commission

280 Slater Street

P.O. Box 1046, Station B

Ottawa, ON K1P 5S9

CANADA

Tel.: 613-995-5894 or 1-800-668-5284 (in Canada only)

Fax: 613-995-5086

Email: [email protected]

Website: nuclearsafety.gc.ca

Facebook: facebook.com/CanadianNuclearSafetyCommission

YouTube: youtube.com/cnscccsn

Twitter: @CNSC_CCSN

LinkedIn: linkedin.com/company/cnsc-ccsn

Publishing history December 2016 Version 1.0

April 2017 Version 1.1 – Administrative updates to sections 2.1 (to match the French

document) and 3.2.4, and to the definition of “environmental effects” in the

glossary

September 2020 Version 1.2 – Administrative updates throughout to reflect the Impact Assessment

Act

file:///C:/Users/huntj/AppData/Roaming/OpenText/DM/Temp/nuclearsafety.gc.camailto:[email protected]://www.nuclearsafety.gc.ca/http://www.facebook.com/CanadianNuclearSafetyCommissionhttp://www.youtube.com/cnscccsnhttps://twitter.com/CNSC_CCSNhttps://www.linkedin.com/company/cnsc-ccsn/

September 2020 REGDOC-2.9.1, Environmental Principles, Assessments and Protection Measures

i

Preface

This regulatory document is part of the CNSC’s environmental protection series of regulatory documents.

The full list of regulatory document series is included at the end of this document and can also be found

on the CNSC’s website.

REGDOC-2.9.1, Environmental Principles, Assessments and Protection Measures, describes:

the CNSC’s principles for environmental protection

for all nuclear facilities or activities that interact with the environment, the scope of an environmental

review and the roles and responsibilities associated with an environmental review

the CNSC’s requirements and guidance to applicants and licensees for developing environmental

protection measures, including an environmental risk assessment (ERA) where required, for both new

and existing facilities or activities

This document is Version 1.2. It supersedes Version 1.1, which was published in April 2017.

Environmental protection for nuclear facilities and activities is done in accordance with the Nuclear

Safety and Control Act (NSCA) and the regulations made under it. The CNSC requires the environmental

effects of all nuclear facilities or activities to be considered and evaluated when licensing decisions are

made.

This document will be used to assess licence applications for proposed new nuclear facilities or activities,

licence applications for existing facilities or activities (renewals and amendments), and environmental

protection measures, as follows:

all licence applications that demonstrate potential interactions between the facility or activity and the

environment are subject to an environmental review

for each facility or activity that has direct interactions with the environment, the applicant or licensee

must demonstrate that environmental protection measures are or will be in place

where an environmental risk assessment (ERA) is required for a facility or activity (details are

included in this regulatory document):

the ERA is subject to regular updates (at least every five years, and whenever a significant change

occurs in either the facility or activity that could alter the nature (type or magnitude) of the

interaction with the environment within the ERA predictions)

the licensee’s ERA informs an environmental review

In all cases, the environmental review, the environmental protection measures and the ERA (where

required) are commensurate with the scale and complexity of the environmental risks associated with the

nuclear facility or activity.

Note: For facilities or activities other than Class I nuclear facilities and uranium mines and mills, the

CNSC reviews every licence application to verify that there are no significant interactions with the

environment (for example, for most Class II facilities, such as hospitals and universities, and for the use

and transport of nuclear substances and radiation devices, there is no interaction with the environment). If

the CNSC’s review of the application determines that the facility or activity:

(a) has potential interactions with the environment and that additional consideration of environmental protection measures is warranted, the information in this document may be applied in a graded

manner

(b) does not interact with the environment, then only the CNSC’s guiding principles for environmental protection (in section 2.1 of this document) are relevant as guidance for such facilities or activities

http://www.nuclearsafety.gc.ca/eng/


ii

Early engagement with CNSC staff is encouraged for facilities or activities with potential interactions

with the environment or for applicants uncertain as to their facility’s or activity’s potential for interaction

with the environment. CNSC staff can provide facility- or activity-specific guidance to assist applicants

and licensees.

A document that shows the changes made to REGDOC-2.9.1, Version 1.1 is available from the CNSC

upon request.

For information on the implementation of regulatory documents and on the graded approach, see

REGDOC-3.5.3, Regulatory Fundamentals.

The words “shall” and “must” are used to express requirements to be satisfied by the licensee or

licence applicant. “Should” is used to express guidance or that which is advised. “May” is used to

express an option or that which is advised or permissible within the limits of this regulatory document.

“Can” is used to express possibility or capability.

Nothing contained in this document is to be construed as relieving any licensee from any other

pertinent requirements. It is the licensee’s responsibility to identify and comply with all applicable

regulations and licence conditions.


Table of Contents

1. Introduction ........................................................................................................................1

1.1 Purpose................................................................................................................................ 1

1.2 Scope ................................................................................................................................... 1

1.3 Relevant legislation ............................................................................................................. 2

1.4 National and international standards ................................................................................... 3

1.5 CNSC contact information .................................................................................................. 4

2. The CNSC’s Environmental Protection Principles ........................................................5

2.1 The CNSC’s guiding principles for protection of the environment .................................... 5

2.2 The CNSC’s environmental protection framework ............................................................ 5

2.3 Other jurisdictions and federal departments ....................................................................... 8

2.4 Public and Indigenous engagement .................................................................................... 9

3. Environmental Reviews ...................................................................................................10

3.1 Impact assessments under the Impact Assessment Act...................................................... 10

3.2 Federal lands reviews under the Impact Assessment Act .................................................. 10

3.3 Ongoing environmental assessments under CEAA 2012 ................................................. 11

3.4 Environmental assessments under provincial regimes and land claim agreements .......... 11

3.5 Environmental protection reviews under the NSCA......................................................... 11

4. Environmental Protection Measures..............................................................................13

4.1 Environmental risk assessment ......................................................................................... 13

4.1.1 Complexity of the environmental risk assessment ............................................... 14

4.2 Effluent and emissions control and monitoring ................................................................ 17

4.2.1 Control of environmental releases ....................................................................... 18

4.2.2 Monitoring of releases to the environment .......................................................... 19

4.3 Environmental monitoring ................................................................................................ 21

4.4 Public dose ........................................................................................................................ 23

4.5 Groundwater protection and monitoring ........................................................................... 23

4.6 Environmental management system ................................................................................. 24

4.6.1 Environmental emergency preparedness ............................................................. 27

4.6.2 Other considerations ............................................................................................ 27

Appendix A: Environmental Assessments Under CEAA 2012 ...............................................28

A.1 Environmental assessment under CEAA 2012 conducted by the CNSC ......................... 30


A.2 Key steps for an environmental assessment under CEAA 2012 ....................................... 32

A.3 Specific CEAA 2012 environmental assessment requirements ........................................ 36

Appendix B: Characterization of the Baseline Environment for an Environmental

Assessment Under CEAA 2012 .......................................................................................41

B.1 Atmospheric environment ................................................................................................. 41

B.2 Surface water environment ............................................................................................... 42

B.3 Aquatic environment ......................................................................................................... 42

B.4 Geological and hydrogeological environment .................................................................. 43

B.5 Terrestrial environment ..................................................................................................... 44

B.6 Ambient radioactivity ....................................................................................................... 45

B.7 Human health .................................................................................................................... 45

B.8 Indigenous land and resource use ..................................................................................... 45

Appendix C: Environmental Effects for an Environmental Assessment Under

CEAA 2012 .......................................................................................................................47

C.1 Atmospheric environment ................................................................................................. 47

C.2 Surface water environment ............................................................................................... 47

C.3 Aquatic environment ......................................................................................................... 48

C.4 Geological and hydrogeological environment .................................................................. 48

C.5 Terrestrial environment ..................................................................................................... 49

C.6 Ambient radioactivity ....................................................................................................... 49

C.7 Human health .................................................................................................................... 49

C.8 Indigenous land and resource use ..................................................................................... 50

Appendix D: Sample Matrix of Biophysical Interactions ........................................................51

Glossary ........................................................................................................................................53

References .....................................................................................................................................54

Additional Information ...............................................................................................................56


1

Environmental Principles, Assessments and Protection Measures

1. Introduction

1.1 Purpose

Environmental protection for nuclear facilities and activities is done in accordance with the

Nuclear Safety and Control Act (NSCA) and the regulations made under the NSCA. This

legislation includes provisions to ensure that licensees are adequately protecting the environment

and the health, safety and security of persons. The CNSC requires the environmental effects of all

nuclear facilities or activities to be considered and evaluated when licensing decisions are made.

This regulatory document provides information to applicants and licensees on protecting the

environment and the health of persons, including:

identification of facility or activity interactions with the environment and the public

identification and mitigation of potential environmental effects associated with these

interactions

design and implementation of effluent and emission release measures and of the

environmental monitoring measures to confirm or test the predictions and the actual effects

periodic assessments of the environmental protection measures and the licensee’s

performance

In particular, this regulatory document describes:

the CNSC’s principles for environmental protection

for all nuclear facilities or activities that interact with the environment, the scope and type of

environmental review, commensurate with the scale and complexity of the environmental

risks

the CNSC’s requirements and guidance to applicants and licensees for developing

environmental protection measures, including an environmental risk assessment (ERA) where

required, for both new and existing facilities or activities

1.2 Scope

This regulatory document clarifies the CNSC’s expectations of applicants and licensees, and

provides guidance for protecting the environment and the health of persons.

This document will be used to assess licence applications for proposed new nuclear facilities or

activities, licence applications for existing facilities or activities (renewals and amendments), and

environmental protection measures:

all licence applications that demonstrate potential interactions between the facility or activity

and the environment are subject to an environmental review

for each facility or activity that has direct interactions with the environment, the applicant or

licensee must demonstrate that environmental protection measures are or will be in place


2

where an ERA is required for a facility or activity (details are included in this regulatory

document):

the ERA is subject to regular updates (at least every five years, and whenever a

significant change occurs in either the facility or activity that could alter the nature (type

or magnitude) of the interaction with the environment

the licensee’s ERA informs an environmental review

In all cases, the environmental review, the environmental protection measures and the ERA

(where required) are commensurate with the scale and complexity of the environmental risks

associated with the nuclear facility or activity.

For facilities or activities other than Class I nuclear facilities and uranium mines and mills, the

CNSC reviews every licence application to verify that there are no significant interactions with

the environment (for example, for most Class II facilities, such as hospitals and universities, and

for the use and transport of nuclear substances and radiation devices, there is no interaction with

the environment). If the CNSC’s review of the application determines that the facility or activity:

has potential interactions with the environment and that additional consideration of environmental protection measures is warranted, the information in this document may be

applied in a graded manner

does not interact with the environment, then only the CNSC’s guiding principles for environmental protection (in section 2.1 of this document) are relevant as guidance for such

facilities or activities

Early engagement with CNSC staff is encouraged for facilities or activities with potential

interactions with the environment or for applicants uncertain as to their facility’s or activity’s

potential for interaction with the environment. CNSC staff can provide facility- or activity-

specific guidance to assist applicants and licensees.

Note: The intent of these requirements is not to replace or duplicate other federal, provincial or

territorial, and municipal legislation with which licensees must comply. Where applicable,

meeting the existing legislative requirements is adequate for meeting the requirements of this

regulatory document.

1.3 Relevant legislation

The following provisions of the NSCA and the regulations made under it are relevant to this

document:

NSCA: o subsection 24(4) o subsection 24(5)

General Nuclear Safety and Control Regulations: o paragraph 3(1)(f) o paragraphs 12(1)(c) and (f)


3

Class I Nuclear Facilities Regulations: o paragraphs 3(e), (g), (h) and (j); o paragraphs 4(c) and (e); o paragraphs 5(b), (i), (j) and (k) o paragraphs 6(h), (i), (j) and (k) o paragraphs 7(e), (f), (g), (h), (i) and (k) o paragraph 8(b)

Class II Nuclear Facilities and Prescribed Equipment Regulations: o paragraph 3(p) o paragraphs 5(e), (f), (h) and (i)

Radiation Protection Regulations: o paragraphs 4(a) and (b) o subsections 6(1) and (2) o subsection 13(1)

Nuclear Substances and Radiation Devices Regulations: o paragraphs 3(1)(b) o paragraph 31(1)(i)

Uranium Mines and Mills Regulations: o subparagraph 3(a)(v) o subparagraphs 3(c)(ii), (iii), (v), (vi), (vii), (viii), (ix) and (x) o subparagraphs 3(d)(i) and (vi)

The Impact Assessment Act (IAA) applies in the following instances:

designated projects as defined in section 2 of the IAA

projects proposed to be carried out on federal lands, as defined in section 82 of the IAA

Under section 182 of the IAA, any environmental assessment of a designated project by the

CNSC commenced under the Canadian Environmental Assessment Act, 2012 (CEAA 2012), in

respect of which a decision has not yet been issued before the coming into force of the IAA, is

continued under CEAA 2012 as if that Act had not been repealed.

The CNSC also considers pertinent legislation from other government departments, including:

Canadian Environmental Protection Act, 1999

Fisheries Act

Species at Risk Act

Migratory Birds Convention Act, 1994

1.4 National and international standards

The following standards from the CSA Group are relevant to this regulatory document:

CAN/CSA ISO-14001, Environmental Management Systems – Requirements with Guidance for Use (2004 edition or successor editions) [1, 2]

CSA N288.1, Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities [3]

CSA N288.4, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills [4]

CSA N288.5, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills [5]


4

CSA N288.6, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills [6]

CSA N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills [7]

The CNSC licensing process ensures that applicable regulatory documents are considered for

licensing applications. The information required to comply with those regulatory documents may

contribute to meeting the requirements in this document. All regulatory documents are available

on the CNSC website.

1.5 CNSC contact information

The applicant or licensee should engage with CNSC staff early in the planning process (before

submission of a licence application) to identify the applicable regulatory documents and confirm

an understanding of the licensing process.

To contact the CNSC:

Tel.: 613-995-5894 or 1-800-668-5284 (in Canada only)

Fax: 613-995-5086

Email: [email protected]

file:///C:/Users/gagnonc/Desktop/nuclearsafety.gc.ca/eng/acts-and-regulations/regulatory-documentsmailto:[email protected]


5

2. The CNSC’s Environmental Protection Principles

Protecting the environment is part of the CNSC’s mandate. The CNSC requires the environmental

effects of all facilities or activities to be evaluated and considered when licensing decisions are

made (see figure 1). For each licensing decision, the CNSC (the Commission or a Designated

Officer) must be satisfied that the applicant or licensee will make adequate provision for the

protection of the environment and the health and safety of persons before a licence can be

granted.

2.1 The CNSC’s guiding principles for protection of the environment

The CNSC regulates nuclear facilities and activities in Canada to protect the environment and the

health and safety of persons in a manner that is consistent with Canadian environmental policies,

acts and regulations and with Canada’s international obligations.

For each facility or activity that has direct interactions with the environment, the CNSC must

determine that the licensee or applicant has made adequate provision for the protection of the

environment. The applicant or licensee’s licence application shall demonstrate (through

performance assessments, monitoring or other assessments) that their environmental protection

measures:

are commensurate with the level of risk associated with the activity

recognize that uncertainty exists in science and account for this uncertainty: o by keeping all releases to the environment as low as reasonably achievable

(ALARA), social and economic factors being taken into account for nuclear

substances [8]

o through the application of the best available technology and techniques economically achievable (BATEA) for hazardous substances

respect the precautionary principle, the “polluter pays” principle, and the concepts of pollution prevention, sustainable development and adaptive management

are assessed against performance indicators and targets that are based on sound science

The following sections of this regulatory document provide information on how to meet these

principles. The CNSC assesses proposed alternative approaches and takes into account the views

and proposals of the licensee concerning their individual situations.

2.2 The CNSC’s environmental protection framework

The CNSC’s environmental protection safety and control area (SCA) covers measures that

identify, control and monitor all releases of radioactive and hazardous substances and effects on

the environment from facilities or as the result of licensed activities.

The applicant’s or licensee’s environmental protection measures should address all aspects of the

CNSC’s environmental protection SCA that are relevant to the facility or activity. The scope and

complexity within each measure should be commensurate with the nature and scale of the

interactions with the environment that may result from the facility or activity.

Note: The CNSC uses the term “environmental protection measures”. The elements in these

measures may be referenced by applicants and licensees in their “environmental protection

programs”. Applicants and licensees are not required to update their management system or other

documents to reflect the term “environmental protection measures”, but they must meet the

requirements listed in this document.


6

Figure 1: Ensuring adequate provision for protection of the environment

Licence application /

project description

May include the applicant or licensee s environmental risk assessment (ERA)

IA under the Impact Assessment Act

- for designated projects listed under the Physical Activities Regulations or designated by the Minister

- refer to MOU with the Impact Assessment

Agency of Canada

EPR under the NSCA- for projects not subject to the IAA or other

applicable EA legislation

- carried out at every phase of the lifecycle

Licensee s environmentalprotection measures

- environmental risk assessment (ERA)- environmental management system- effluent control and monitoring- environmental monitoring

Compliance monitoring

--------------------------------------------------- Protection of the environment ------------------------------------------------------

To reflect updates to the licensee s ERA whenever there has been significant change to the facility or

activity, or in the science on which the ERA is based

Application

Environmental review

Licence and ongoing protection of the

environment

----

----

----

----

----

----

----

----

----

----

----

-- P

ub

lic

an

d In

dig

eno

us

en

gage

me

nt

----

----

----

----

----

----

----

----

---

No interaction with the environment

- environmental protection measures are not required

Licensing process under the NSCA

Is the projecta designated project

under the IAA?

Yes No

Is the projecta project on federal lands in

accordance with section 82of the IAA?

Yes

Is the projectsubject to a provincial /territorial / land claim

EA regime?

No

Does the project have potential

environmental interactions?

No

Yes

No

Federal lands review under the IAA

- CNSC as federal authority conducts federal lands review

Provincial / territorial / land claim agreement EA

- CNSC participates as technical expert

Yes


7

Figure 2 shows the cyclical nature of an ERA and how the ERA links to the effluent monitoring

and environmental monitoring measures, illustrating how the ERA and the monitoring measures

inform each other.

Figure 2: Interrelationships between the ERA and monitoring

Environmental risk assessment (ERA)

Ecological and Human Health (EcoRA and HHRA)Radionuclides - hazardous substances - physical stressors

ERA predictionsCSA N288.1, CSA N288.6

Effluent monitoringCSA N288.5

Environmental and groundwater monitoring

CSA N288.4, CSA N288.7

Supplementary studiesand

current scienceRevi

ew a

nd

revi

se E

RA w

ith

acc

um

ula

ted

mo

nit

ori

ng

dat

a

Rev

iew

an

d r

evis

e ER

A w

ith

an

y si

te-s

pec

ific

stu

die

s on

mo

del p

aram

eter

s, a

ssu

mp

tio

ns

and

ne

w s

cie

nce

Environmental management system (EMS) ISO 14001

The CNSC’s regulatory framework for environmental protection:

respects other federal and provincial environmental legislation

applies the following standards in a graded approach, commensurate with risk:

CSA N288.4, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills [4]

CSA N288.5, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills [5]

CSA N288.6, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills [6] (and, for further information on human exposure

modelling, see CSA N288.1, Guidelines for calculating derived release limits for

radioactive material in airborne and liquid effluents for normal operation of nuclear

facilities [3])


8

CSA N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills [7]

CAN/CSA ISO 14001, Environmental Management Systems – Requirements with Guidance for Use [1, 2]

These CSA standards apply to Class I nuclear facilities and uranium mines and mills. The CSA

standards ensure that the risks associated with releases to the environment are continually

assessed and mitigated; that releases are controlled and monitored; and that the environment is

monitored. See section 4 for additional information on the application and implementation of

these CSA standards, as well as other elements of environmental protection (for example, an

environmental management system (EMS)).

For facilities or activities other than Class I nuclear facilities and uranium mines and mills, the

CNSC reviews every licence application to verify that there are no significant interactions with

the environment (for example, for most Class II facilities, such as hospitals and universities, and

for the use and transport of nuclear substances and radiation devices, there is no interaction with

the environment). If the CNSC’s review of the application determines that the facility or activity

has potential interactions with the environment (such as planned releases of radioactive or

hazardous substances to the environment) and that additional consideration of environmental

protection measures is warranted, the applicant or licensee applies the information in section 4 to

their environmental protection measures in a graded approach, commensurate with risk.

The CNSC also regulates many facilities and activities that do not have any interactions with the

environment (that is, the facility or activity has no direct releases to the environment). A licence

application that describes the nature of the proposed licensed activities is considered sufficient for

ensuring protection of the environment, provided that CNSC staff conclude the facility or

activities do not interact with the environment. In this case, the remaining information in this

document does not apply to such facilities or activities.

Early engagement with CNSC staff is encouraged for facilities or activities with potential

interactions with the environment. CNSC staff can provide facility- or activity-specific guidance

to assist applicants and licensees.

2.3 Other jurisdictions and federal departments

The CNSC cooperates with other jurisdictions and federal departments to protect the

environment. Where appropriate, the CNSC may enter into formal arrangements to increase the

effectiveness of environmental protection. For example, the CNSC holds memoranda of

understanding (MOUs) with other federal departments (such as Fisheries and Oceans Canada,

Environment and Climate Change Canada). A complete list of MOUs is available on the CNSC’s

website.

When a proposed facility or activity must also comply with provincial or territorial legislation,

the CNSC collaborates and coordinates the environmental protection processes where possible to

increase efficiency and reduce duplication.

http://nuclearsafety.gc.ca/eng/acts-and-regulations/memorandums-of-understanding/index.cfmhttp://nuclearsafety.gc.ca/eng/acts-and-regulations/memorandums-of-understanding/index.cfm


9

2.4 Public and Indigenous engagement

Participation opportunities for the public and for Indigenous groups are an important component

of the CNSC’s environmental reviews and licensing processes. The CNSC determines the

appropriate level of participation opportunities on a case-by-case basis. The criteria include:

interests of the public and Indigenous groups

the complexity of the facility or activity and its potential interactions with the environment and the public

additional factors such as other jurisdictional mandates or type of decision

For further information on the CNSC’s expectations of licensees for public and Indigenous

engagement, refer to:

REGDOC-3.2.1, Public Information and Disclosure [9]

REGDOC-3.2.2, Indigenous Engagement [10]


10

3. Environmental Reviews

The CNSC requires that the environmental effects of all nuclear facilities or activities be

considered and evaluated when licensing decisions are made. All licence applications that

demonstrate potential interactions with the environment are subject to an environmental review

commensurate with the scale and complexity of the environmental risks associated with the

facility or activity.

Early in the licensing process, CNSC staff determine which type of environmental review applies

by considering the information provided by the applicant or licensee in their initial submission

and supporting documentation. The information below outlines the different types of

environmental reviews that may be applicable under the CNSC’s current regulatory framework.

The CNSC ensures that the public has an opportunity to participate in the environmental review,

and Indigenous consultation and engagement activities are integrated into the review process, to

the extent possible.

3.1 Impact assessments under the Impact Assessment Act

Impact assessments are conducted on projects identified as having the greatest potential for

adverse environmental effects in areas of federal jurisdiction, either listed as a “designated

project” in the Physical Activities Regulations or as designated by the Minister of Environment.

The scope of impact assessments subject to the Impact Assessment Act (IAA) includes the

environmental, health, social and economic effects – both positive and negative – of a proposed

project.

The Impact Assessment Agency of Canada (IAAC) leads the conduct of impact assessments for

all designated projects subject to this legislation and works in collaboration with the CNSC to

review projects that are also subject to regulation under the NSCA. Nuclear projects to be

assessed under the IAA are subject to an integrated impact assessment that is carried out by a

review panel. An integrated impact assessment means having a single assessment process with

the shared objective that the requirements of both the IAA and the NSCA are discharged as “one

project, one assessment”.

A memorandum of understanding (MOU) established between the CNSC and the IAAC outlines

the roles and responsibilities of each organization and helps guide collaboration into conducting

integrated impact assessments under the IAA. The MOU confirms each organization’s

commitment to ensuring that the principle of “one project, one assessment” is followed in

reviewing designated projects regulated by the CNSC, and that any reviews are conducted in an

efficient and effective manner, without unnecessary delays or duplication of effort.

For more information, see:

Impact Assessment Agency of Canada

Impact Assessment Act

MOU between the CNSC and the Impact Assessment Agency of Canada

3.2 Federal lands reviews under the Impact Assessment Act

Projects not listed in the Physical Activities Regulations, but proposed to be carried out on federal

lands and requiring a decision by the CNSC as a federal authority, are subject to federal lands

reviews under the IAA.


11

Upon receipt of a licence application for proposed activities to be carried out on federal lands,

CNSC staff review the application and make a determination whether the proposal is subject to a

federal lands review under the IAA. If a federal lands review is required, CNSC staff post a

notice of this determination on the Canadian Impact Assessment Registry website, review the

proposal according to the factors provided in section 84 of the IAA, and provide their

recommendation to the Commission. The Commission is responsible to make the decision in

determining whether the completion of the proposed project on federal lands is likely to cause

significant adverse environmental effects.

The Designated Classes of Projects Order describes the classes of projects on federal lands that

are designated by the Minister of Environment as causing only insignificant adverse

environmental effects and that are, therefore, exempt from the federal lands requirements of the

IAA.

The IAAC is developing further guidance and materials on federal lands reviews in collaboration

with federal authorities, including the CNSC.

3.3 Ongoing environmental assessments under CEAA 2012

Projects with environmental assessments (EA) already initiated under the Canadian

Environmental Assessment Act (2012) (CEAA 2012) and led by the CNSC will continue under

their current processes as per the transition provision (section 182) of the IAA.

An EA under CEAA 2012 is carried out early in the licensing process (at the beginning of the

project’s lifecycle) and serves as a planning tool. The process for an EA under CEAA 2012 is

described in appendix A.

The CNSC has in place Generic Guidelines for the Preparation of an Environmental Impact

Statement pursuant to the Canadian Environmental Assessment Act, 2012. This document

informs proponents of the information requirements for the preparation of an environmental

impact statement (EIS) for a project that requires an EA under CEAA 2012. An EIS is a report

written by a proponent that presents the technical studies and findings of an EA.

3.4 Environmental assessments under provincial regimes and land claim agreements

Some proposed nuclear projects may be subject to provincial EA legislation but not subject to the

IAA. Also, in certain parts of Canada (for example, Yukon, Northwest Territories, Nunavut, parts

of Quebec and parts of Newfoundland and Labrador), EA processes established under land claim

agreements apply, and the IAA does not. In both cases, the CNSC acts as a technical advisor and

is an active participant at all stages of the EA process; however, the CNSC has no role in making

the EA decision. The Commission retains decision-making authority on licensing matters, and

uses the information gathered in the EA process to inform its licensing decision under the NSCA.

When multiple jurisdictions are involved, these processes are harmonized as much as possible to

reduce duplication and promote efficiency.

3.5 Environmental protection reviews under the NSCA

The CNSC conducts environmental protection reviews (EPRs) for all licence applications with

potential environmental interactions in accordance with its mandate under the NSCA to ensure

the protection of the environment and the health of persons. An EPR is a science-based

environmental technical assessment by CNSC staff as set out in the NSCA. Where there are


12

potential environmental interactions, an EPR under the NSCA is conducted for projects not

subject to the IAA or other applicable EA legislation (described above).

An EPR describes the outcome of CNSC staff’s review of licensing and environmental

compliance activities conducted under the NSCA. This review serves to assess whether the

applicant or licensee will, in carrying on a licensed activity, make adequate provision for the

protection of the environment and health of persons. This assessment is commensurate with the

scale and complexity of the environmental risks associated with the nuclear facility or activity.

An EPR under the NSCA is a component of the CNSC licensing and compliance verification

process. It is carried out as part of the CNSC’s review of all licence applications of facilities and

activities that have potential interactions with the environment. CNSC staff assess the

environmental and health effects of nuclear facilities and activities at every phase of the lifecycle

or duration. At each phase (that is, for each licence application), CNSC staff consider all future

phases of the lifecycle, taking into consideration all available information. As with all other safety

and control areas (SCAs), an EPR under the NSCA is a process of ongoing verification related to

the environmental protection SCA.

An EPR under the NSCA is primarily based on information that the applicant or licensee is

required to submit to the CNSC through the established licensing process, such as the licence

application and its supporting documentation, and information on environmental protection

measures. An EPR under the NSCA is also based on compliance and technical assessment

activities completed by CNSC staff (for example, reviews of annual environmental monitoring

reports and environmental risk assessments). An EPR under the NSCA may also be supported by

independent verification activities, such as the CNSC’s independent environmental monitoring

program (IEMP), as well as relevant regional health studies, monitoring programs and Indigenous

knowledge studies.

Within a licensing process, the results of the EPR can be presented in a supporting report to

accompany staff’s licensing report to the Commission, or it can be reported directly in that staff

licensing report (known as a Commission Member Document (CMD)). Outside of a licensing

process, the results of the EPR can be presented in a stand-alone report that is posted on the

CNSC website. An EPR report is intended for two key audiences – members of the public and

Indigenous groups, and within the context of a licensing process, the Commission. The EPR

report is prepared with the following objectives:

publishing a clear report or section that provides transparency to the public and Indigenous

groups on CNSC staff’s technical assessment

providing evidence-based information to inform the Commission’s licensing decision (note

that no decision is made on the EPR report itself)


13

4. Environmental Protection Measures

The necessary measures for environmental protection are determined on a facility- or activity-

specific basis. Note: Not every facility or activity is required to have every environmental

protection measure described in this section. The applicant or licensee may address certain

requirements by demonstrating that a particular measure is not necessary or does not apply to that

facility or activity. A licence application that describes the nature of the proposed licensed

activities is considered sufficient for ensuring protection of the environment, provided CNSC

staff conclude that the facility or activities do not interact with the environment.

4.1 Environmental risk assessment

An ERA is a systematic process that identifies, quantifies and characterizes the risk posed by

contaminants (nuclear or hazardous substances) and physical stressors in the environment. It is a

practice or methodology that provides science-based information to support decision-making and

to prioritize the implementation of mitigation measures.

The applicant or licensee’s ERA informs an environmental review. The ERA:

identifies facility- or activity-specific characteristics and site-specific environmental

characteristics

identifies interactions between those characteristics

assesses the likelihood and significance of these interactions and the resulting potential

effects on the environment and the public

In conjunction with regulatory monitoring requirements, the ERA and its associated performance

predictions serve as the basis for control and monitoring of releases, environmental monitoring,

and any supplementary studies. All of these measures are interrelated and managed within the

environmental management system (EMS). For additional information on an EMS, see

section 4.6.

The initial ERA for a new facility or activity is based on best estimates of the facility- or activity-

specific characteristics. These characteristics are combined with sufficient environmental

characterization (such as baseline) to support the assessment of potential interactions with the

environment and the potential for associated environmental effects.

The ERA uses the facility- or activity-specific estimates of physical disturbances and chemical

releases (both nuclear and hazardous substances) to predict:

the source terms of gaseous and liquid discharges

the transport of nuclear and hazardous substances through the environment

public exposure and dose

exposure and effects on representative biota

changes in habitat and effects on species that rely on that habitat

These predictions establish the basis for the CNSC’s compliance program for that facility or

activity.

The applicant or licensee incorporates the results of the initial ERA into their EMS, including the

effluent and environmental monitoring measures. The predictions for physical disturbances and


14

releases, and the associated environmental behavior and potential effects, are measured and tested

using site-specific monitoring.

The initial ERA submitted for licensing purposes for a new facility or activity is primarily

predictive as it involves assessing the potential effects of a hypothetical facility or activity. As a

facility or activity moves through its lifecycle, the ERA is periodically reviewed and revised (see

section 4.1.2) using the accumulated site knowledge derived from operational experience,

monitoring, special investigations, incorporation of advances in scientific knowledge and, where

available, Indigenous traditional knowledge.

These “living” ERAs, which are informed by real data from monitoring programs (emissions,

effluents, environmental) and current science, are used to assess if the original environmental

impact predictions are exceeded or may be exceeded in the future. In this manner, the initial ERA

evolves through the life of the facility or activity, remaining current and becoming an

increasingly more powerful site-specific tool.

Requirements

For Class I facilities and uranium mines and mills, the licensee shall conduct an ERA in

accordance with CSA N288.6, Environmental risk assessments at Class I nuclear facilities and

uranium mines and mills [6].

The ERA shall be completed in a systematic, scientifically defensible manner that identifies,

quantifies and characterizes the risk posed by releases of nuclear and hazardous substances and

physical disturbances (stressors) on representative human and non-human biota. The licensee

shall ensure that the ERA includes, as applicable to the facility or activity, both an ecological risk

assessment (EcoRA) for the environment and a human health risk assessment (HHRA) for

members of the public.

Guidance

For facilities or activities other than Class I nuclear facilities and uranium mines and mills, for

which the CNSC has determined that there are direct interactions with the environment, the

licensee should use the ERA process described in CSA N288.6 [6] in a graded approach as

appropriate to their circumstances. For many of these facilities, a simple screening assessment (as

described in CSA N288.6) is adequate. Note: Although CSA N288.6 was developed for Class I

facilities and uranium mines and mills, the methodology and general principles can be applied to

other facilities and activities regulated by the CNSC.

Early engagement with the CNSC is encouraged for facilities and activities that are not

specifically addressed by CSA N288.6 [6]. The CNSC can provide facility- or activity-specific

guidance to assist licensees.

4.1.1 Complexity of the environmental risk assessment

Requirements

The applicant or licensee shall identify facility characteristics and activities that may interact with

the environment during the relevant phase of the facility or activity’s lifecycle (for example, site

preparation, construction, operation and decommissioning).


15

This characterization shall include descriptions of facility- or activity-specific performance with

respect to:

physical disturbances (for example, footprint for surface structures, below-grade structures, diversions or flow alterations of surface or groundwater)

emissions released to the environment

effluents released to the environment

The facility or activity characterization shall be of sufficient detail to assess the potential for

effects arising from the proposed maximum quantities and anticipated volumes and flow rates for

releases associated with the facility or activity.

The applicant or licensee shall present a characterization of the baseline environment (that is, the

environment before any development of the facility or activity has started) for any portion of the

environment where the site characterization indicates potential for interaction.

The applicant or licensee shall use the facility- or activity-specific characterization and the local

environmental baseline characterization to identify the potential interactions between the facility

or activity and the surrounding environment. Note that these identified interactions will become

the focus of further stages within the ERA.

The applicant or licensee shall use the potential environmental interactions to support their

justification as to the level of complexity for the ERA in accordance with CSA N288.6,

Environmental risk assessments at Class I nuclear facilities and uranium mines and mills [6].

Guidance

ERAs may be completed in a tiered manner reflecting the complexity of the disturbances and

releases associated with the facility or activity and with the complexity or sensitivity of the

surrounding environment. This tiered approach allows the rapid completion of simple screening

risk assessments for facilities or activities with limited interaction with the receiving environment

or the public. However, it also allows for progressively more complex quantitative assessments

for facilities or activities when warranted by the severity and the spatial and temporal extent of

potential effects (see figure 3).


16

Figure 3: Tiered options for environmental risk assessments (simplified from

CSA N288.6 [6])

Minimal environmental

impact

Start

Site characterization facility environment

Screening

Preliminary quantitative

analysis

Detailed quantitative

analysis

Minimal environmental

impact

No environmental

interactionInitial

screening results

Determine theneed for, and extent of,

monitoring and mitigation(see figure 2)

Environmental protection measures are not required

Reviewing and revising the environmental risk assessment

Where an ERA exists, the licensee shall review and revise the ERA in accordance with CSA

N288.6, Environmental risk assessments at Class I nuclear facilities and uranium mines and

mills [6]; taking into consideration whether there has been:

a significant change in the facility or activity that could alter the nature (type or magnitude) of the interactions with the environment (such as modification, expansion or

refurbishment of the facility) within the ERA predictions

any transition to a new phase in the lifecycle (such as a transition to licence to operate, decommission or abandon) where the application for the new licensing phase includes

any interactions with the environment that were not previously captured in the ERA


17

The ERA shall be revised with site knowledge derived from:

operational experience (for example, performance of mitigation measures such as effluent control systems)

results of monitoring

supplementary studies

incorporation of recent developments in scientific knowledge

The revised ERA shall be used to assess the environmental performance of the facility or activity.

The ERA shall also be used to predict continued future performance and associated

environmental effects of the facility or activity.

If the revised ERA indicates that the nature, extent and significance of environmental effects are

greater than predicted, the licensee shall:

evaluate the environmental effects in terms of risk

investigate mitigation measures as necessary

identify any changes needed to the effluent and emissions monitoring measures resulting from any mitigation measures

4.2 Effluent and emissions control and monitoring

Controls on environmental releases are established to provide protection to the environment and

to respect the principles of sustainable development and pollution prevention.

Requirements

The preventive and control measures shall be based on the potential risks to the environment that

the facility or activity may pose.

The effluent and emissions control and monitoring shall:

identify and document the infrastructure and activities (such as pipelines or storage) with the

potential for significant accidental release to the environment of nuclear and hazardous

substances and the barriers (such as primary and secondary containment, and liners) to

prevent releases

identify and document the points of release to the environment and the corresponding

preventive control measures and equipment necessary to regulate and control the release of

these nuclear and hazardous substances in the authorized manner

estimate or measure, document and report the quality and quantity of releases to the

environment

verify the nature and quantity of releases against compliance criteria (such as authorized

release limits), performance indicators (such as action levels) and the predictions of releases

used as input parameters for the site-specific ERA

evaluate mitigation measures to further control releases when the monitoring results identify

deviations from the expected performance


18

4.2.1 Control of environmental releases

The effluent and emissions preventive and control measures are established on the basis of best

industry practice, incorporating the application of BATEA, ALARA, process optimization,

continuous improvement and the results of an ERA.

Guidance

A licensee’s effluent and emissions control should address the following:

BATEA assessment of pollution prevention and control technologies:

o design and maintenance of engineered barriers between key waste streams and sources of nuclear and hazardous substances (for example, double-lined piping,

secondary containment and sumps, waste rock pads and pond liners), with

maintenance programs to ensure the integrity of these barriers

o wastewater treatment systems (for example, precipitation and settling systems, ion-exchange columns, evaporators and membrane separation systems such as

reverse osmosis) that minimize the contaminants released to surface waters from

liquid effluent streams with maintenance programs to ensure the availability and

performance of these systems

o air pollution control technology systems (for example, HEPA filters, baghouse filters, wet/dry scrubbers, absorption/adsorption systems) that minimize air

pollutants released to the environment via air emissions through stacks or as

fugitive emissions from the facilities with maintenance programs to ensure the

availability and performance of these systems

BATEA assessment of techniques:

o a focus on BATEA optimization; that is, the application of pollution prevention performance standards, design objectives and best practices to minimize or

eliminate the release of nuclear or hazardous substances to the environment:

both operational and managerial practices that can influence the quality of releases to the environment (for example, upstream and downstream

process optimization, adequate training of staff and effective overall

management of the operation)

application and continual review of action levels as indicators of a potential loss of control of the site-specific environmental protection

measures, to ensure the process is operating within its approved design

specification and normal operating conditions

o ALARA assessments (minimization-focused); that is, the application of radiation protection principles to effectively minimize human and environmental exposure

to nuclear substances

processes and procedures to ensure effective management of the effluent and emission control systems within an EMS (for example, maintenance of treatment systems, timely

replacement of filters, calibration of monitoring equipment and procedures detailing

appropriate responses to action level exceedances)

After the facility or activity is licensed, BATEA assessments of pollution prevention and control

technologies for releases are necessary only where effects exceed, or may exceed, those identified

in the ERA and adaptive management involving the modification or reduction of releases of

specific nuclear or hazardous substances is indicated.


19

Assessments of techniques and the processes and procedures for ensuring effective effluent and

emission control programs should be reviewed as part of the EMS requirement for continuous

improvement.

4.2.2 Monitoring of releases to the environment

In conjunction with specific regulatory monitoring requirements, the ERA provides the technical

foundation and structure for identifying the need for, and details of, effluent and emissions

monitoring. The site-specific effluent and emissions monitoring is designed using the

characterization of the locations, the anticipated volume, chemistry and flow rate of releases, and

the proposed maximum quantities and concentrations of nuclear and hazardous substances

(including their physical, chemical and radiological characteristics).

For facilities and activities with no significant measurable releases to the environment, effluent

and emissions monitoring is not required. In such cases, the licensee should demonstrate (through

engineering or scientific methods) that appropriate barriers and practices are in place, and are

monitored and maintained to prevent releases to the environment.

For facilities and activities where the releases are of low risk or quantities are too low or too

difficult to measure, monitoring is not required. The licensee may estimate emissions based on

site-specific process chemistry and engineering principles.

Requirements

For Class I nuclear facilities and uranium mines and mills, the effluent and emissions monitoring

shall address the requirements in CSA N288.5, Effluent monitoring programs at Class I nuclear

facilities and uranium mines and mills [5].

The effluent and emissions monitoring shall be designed and implemented:

to demonstrate compliance with authorized release limits

to respond to any action levels or other performance indicators, internal objectives or targets set on releases for effluent control

to confirm the adequacy of controls on releases from the source

to provide supportive data required to assess the level of risk on human health and safety and potential effects on the environment as determined by the ERA or regulation

In addition, the licensee shall ensure that the effluent and emissions monitoring:

demonstrates that controlled releases to water frequented by fish are not acutely lethal

supports and assesses the adequacy of any adaptive management measures

For Class I nuclear facilities and uranium mines and mills, the applicant or licensee shall assess

and document the need for action levels. The applicant or licensee shall engage with CNSC staff

on the requirements for establishing and implementing action levels for releases to the

environment.

For facilities and activities subject to the Uranium Mines and Mills Regulations, the licensee shall

develop a facility-specific code of practice that includes, where appropriate, action levels for

releases of nuclear and hazardous substances to the environment.


20

The applicant or licensee shall assess for acute lethality any effluents that are released to water

frequented by fish and that contain hazardous substances that could be considered deleterious

under the Fisheries Act. Meeting existing federal or provincial requirements for toxicity testing

shall be considered as satisfying this requirement. Otherwise, the method(s), frequency of testing

and actions to be implemented as a result of a test failure shall be developed during licensing and

shall be informed by existing standard practices applied to other industrial sectors.

Guidance



licensee should use the process described in CSA N288.5 [5] in a graded approach as appropriate

to their circumstances. Note: Although CSA N288.5 [5] was developed for Class I facilities and

uranium mines and mills, the methodology and general principles can be applied to other

facilities and activities regulated by the CNSC.

The measurement and evaluation of environmental releases are key to verifying the efficacy of

preventive and control measures. The overall process should include feedback mechanisms (both

periodic and continual) to assess and implement actions to achieve performance targets.

Monitoring should be conducted on a temporal scale relevant to the nature and complexity of the

release (such as intermittent, continuous or batch), and should use a standard sampling

methodology (or a non-standard methodology approved by CNSC staff) that is appropriate for the

type of release (see figure 4).

Figure 4: Types of releases that may be associated with a nuclear facility or activity that can

influence sampling methodology and frequency (CSA N288.5 [5])

Effluent and emission monitoring addresses both the nature and quantities of releases of nuclear

and hazardous substances (including wastes). Performance indicators for operational control, such

as action levels (where required), should be established to serve as early indicators of potential

loss of control or deviation from expected quality or quantity of releases. Performance indicators

should be designed to initiate investigation of abnormal situations and, if necessary, result in

corrective measures. Measurement and evaluation should be coordinated to permit timely

corrective action.

For facilities and activities other than Class I nuclear facilities and uranium mines and mills, for

which the CNSC has determined that there are direct interactions with the environment, licensees

should consider incorporating the development of similar environmental performance indicators,

such as action levels, in their effluent and emission monitoring.


21

4.3 Environmental monitoring

Environmental monitoring consists of a risk-informed set of integrated and documented activities

to sample, measure, analyze, interpret and report one or all of:

the concentration of nuclear and hazardous substances in environmental media to assess one or both of:

o the exposure of receptors to those substances

o the potential effects on human health, safety and the environment

the intensity of physical stressors and/or their potential effect on human health and the environment

the physical, chemical and biological parameters of the environment normally considered in the design of the environmental monitoring necessary to support the interpretation of

the results; some examples are supportive data for transport (such as wind velocity) or

toxicity assessment (such as organic carbon or hardness) or measurements at reference

stations (where incorporated in the monitoring)

Requirements

For Class I nuclear facilities and uranium mines and mills, the licensee shall ensure that the

environmental monitoring addresses CSA N288.4, Environmental monitoring programs at

Class I nuclear facilities and uranium mines and mills [4].

The licensee shall use applicable regulatory monitoring requirements and the ERA to identify the

need for and complexity of the environmental monitoring. The licensee shall provide justification

to support whether ERA-derived environmental monitoring is required. In the justification, the

licensee shall address:

characteristics of the licensed facility or activity

characteristics of the surrounding environment

nuclear and hazardous substances and physical stressors

receptors that can be affected

spatial extent of potential exposures

severity, probability, and spatial and temporal extent of any potential biological effects

The licensee shall ensure that the environmental monitoring measures, plans and data provide

sufficient information to assess exposure or potential effects on human health and the

environment due to releases or physical perturbations resulting from the facility or activity.

The licensee shall ensure that the results of the environmental monitoring are used to confirm that

the effects on the environment are within the licensing predictions and adequate provisions are in

place to protect the environment.

Guidance



licensee should use the process described in CSA N288.4, Environmental monitoring programs

at Class I nuclear facilities and uranium mines and mills [4] in a graded approach, as appropriate

to their circumstances. Note: Although CSA N288.4 [4] was developed for Class I facilities and


22



Monitoring for the presence of stressors (physical stressors or nuclear and hazardous substances)

in the environment is sometimes more informative than monitoring the release at the source. The

practice of monitoring ambient air quality is common for atmospheric emissions, especially

fugitive or diffuse emissions (such as radon from ore pads).

The results of the environmental monitoring should:

be used to validate the predictions related to transport of nuclear and hazardous substances through the environment and the magnitude and extent of any effects

predicted in the site-specific ERA to determine if the facility or activity continues to

operate within its predicted environmental performance

be periodically reviewed (in conjunction with the periodic revision and update of the ERA) as to its adequacy for testing the environmental predictions

be modified as necessary to support and assess the adequacy of any adaptive management measures

Environmental monitoring may involve three basic types of monitoring objectives (see CSA

N288.4 [4]):

pathways monitoring

biological effects monitoring

supplementary studies

Pathways monitoring is the most common form of monitoring. It involves sampling and

analyzing abiotic and biotic media that lie along the pathways connecting a source (that is, a

release from a facility or activity) to a receptor (such as non-human biota or the public) to

determine the concentration or level of a contaminant or physical stressor in that medium. This

data, combined with environmental transfer parameters that describe the movement of

contaminants or physical stressors through the environment, may be used to assess the exposure

of the receptor. Some examples of the most common sampling media are:

components of air, water, soil and sediment

vegetation consumed by herbivorous receptors

tissues of prey animals consumed by carnivorous receptors

foodstuffs consumed by humans

Such environmental monitoring is only necessary for those facilities or activities where the

releases have the potential to be measurable within the environment. The monitoring details, with

respect to the analytes being measured (physical stressors, nuclear and hazardous substances) and

the media to be sampled (air, water, and so on), are dependent on the scale and complexity of the

risks associated with the facility or activity.

Biological effects monitoring is used to detect actual measurable biological responses of

organisms to exposure to the stressor. For regulatory purposes, responses at the individual,

population or community level of biological organization are considered to be more relevant as


23

indicators of ecological effects. Some examples of biological effects monitoring that may be

relevant depending on the risk posed by the facility or activity include:

toxicity testing using exposure media (such as effluent receiving waters or exposed sediments)

fish health and population indicators (such as gonadal somatic index and egg production)

monitoring of plant or benthic invertebrate community composition (benthic invertebrates or plants)

Supplementary studies may be conducted to achieve specific well-defined objectives such as:

providing the data required to reduce uncertainty and confounding factors in the ERA

increasing knowledge of the behavior of contaminants and physical stressors in the

environment (for example, refining environmental transfer parameters)

investigating monitoring results that indicate potential deviation from the transport or effects

predictions in the ERA or the licensing basis

4.4 Public dose

Radiological releases to the environment are controlled and monitored by the effluent and

emissions control and monitoring and the environmental monitoring. Results of these monitoring

and control activities are used to determine dose to members of the public.

A human health risk assessment (HHRA) is completed as a sub-element of an ERA for both

nuclear and hazardous substances.

Requirements

The Radiation Protection Regulations define prescribed dose limits for workers and members of

the public, and require doses to be monitored by direct measurement or by estimation of the

quantities and concentrations of any nuclear substance released as a result of a licensed activity.

The Radiation Protection Regulations require licensees to implement a radiation protection

program for protection of the public. The focus for radiation protection within the environmental

protection framework is on radiological protection of the environment and the public.

Guidance

The development of a radiation protection program should be based on a sound policy, strategy

and method for radiation protection and the achievement of ALARA, while taking into

consideration the pathways and critical groups identified in the derived release limits (DRL)

document (CSA N288.1, Guidelines for calculating derived release limits for radioactive

material in airborne and liquid effluents for normal operation of nuclear facilities [3]).

The licensee should design the radiation protection program commensurate with the radiological

hazards associated with the licensed activities, based on an ERA and including radiation exposure

and dose assessments.

4.5 Groundwater protection and monitoring

Groundwater protection is a specialized element of the overall environmental protection

measures. As groundwater flow and associated contaminant transport can be more difficult to


24

detect and delineate than that of surface water, specific requirements and guidance are provided

here.

Groundwater protection is an inter-related system of initiatives, processes and activities with the

overall goal of protecting the quality and quantity of groundwater by minimizing interactions

with the environment from activities associated with a nuclear facility, allowing for effective

management of groundwater resources.

Requirements

For Class I nuclear facilities and uranium mines and mills, the licensee shall ensure that the need

for and design of groundwater protection programs and associated monitoring address CSA

N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and

mills [7].

The applicant or licensee shall implement a groundwater protection program in a graded

approach, appropriate to their circumstances, to:

prevent or minimize releases of nuclear or hazardous substances to groundwater

prevent or minimize the effects of physical stressors on groundwater end uses

confirm that adequate measures are in place to stop, contain, control and monitor any releases and physical stressors that can occur under normal operation

Guidance



applicant or licensee should implement a groundwater protection program and associated

monitoring program in accordance with CSA N288.7, Groundwater protection programs at

Class I nuclear facilities and uranium mines and mills [7] in a graded approach as appropriate to

their circumstances. Note: Although CSA N288.7 [7] was developed for Class I facilities and



Groundwater protection programs are developed on a site-specific basis and should consider the

following elements:

identification of sources of contaminants of concern

investigation of releases under normal operation and source characterization

site characterization

assessment of groundwater end-use

assessment of groundwater vulnerability

development of a groundwater monitoring program

risk management (as required)

4.6 Environmental management system

An environmental management system (EMS) refers to the management of an organization’s

environmental policies, measures and procedures in a comprehensive, systematic, planned and

documented manner. It includes the organizational structure, planning and resources for


25

developing, implementing and maintaining policy for environmental protection and for

continuous improvement by:

identifying and managing environmental risks associated with a facility or activity (see section 3 and section 4.1)

the identification, implementation and maintenance of pollution control activities and technologies (see section 4.2.1)

monitoring of releases (see section 4.2.2)

monitoring of contaminants and for their potential effects in the environment (see section 4.3)

In addition, the EMS should address environmental emergency preparedness.

The EMS serves as the management tool for integrating all of the applicant or licensee’s

environmental protection measures in a documented, managed and auditable process by:

identifying and managing non-compliances and corrective actions within the activities, through internal and external inspections and audits

summarizing and reporting the performance of these activities, both internally (licensee’s management structure) and externally (to the Commission and the public)

training of the personnel involved in these activities

ensuring the availability of resources (such as qualified personnel, organizational infrastructure, technology and financial resources)

defining and delegating roles, responsibilities and authorities essential to effective environmental management

The EMS may be implemented within the licensee’s integrated management system.

Requirements

For Class I nuclear facilities and uranium mines and mills, the licensee shall manage their

environmental protection measures within an EMS that reflects the nature and complexity of their

environmental protection measures.

The licensee shall:

establish, implement and maintain an EMS that meets the requirements set by CAN/CSA ISO 14001, Environmental Management Systems – Requirements with

Guidance for Use (2004 edition or successor editions) [1, 2]

ensure that the scope of the EMS is consistent with the definition of environment, environmental effects and pollution prevention provided in the glossary of this regulatory

document

conduct internal audits at planned intervals so that all elements of the EMS are audited on at least a five-year cycle

conduct an annual management review

Guidance




26

applicant or licensee should manage their environmental protection measures within an EMS that

reflects the nature and complexity of their environmental protection measures.

In addition to the information provided in this regulatory document, the licensee should refer to

the following documents:

CAN/CSA ISO 14001, Environmental Management Systems – Requirements with Guidance for Use (2004 edition or successor editions) [1, 2]

CAN/CSA ISO 14004, Environmental Management Systems – General Guidelines on Principles, Systems and Support Techniques [11]

Note: The CNSC does not consider certification to CAN/CSA ISO 14001 by an authorized

registrar or other independent third party as solely sufficient for demonstrating compliance with

the requirements. The CNSC evaluates all activities in relation to the requirements of this

regulatory document. The CNSC’s compliance verification focuses on the effectiveness of the

EMS rather than on the licensee’s adherence to CAN/CSA ISO 14001 (2004 edition or successor

editions) [1, 2].

During the design of an EMS, the ISO documents provide guidance and information that may be

useful; however, the licensee should note that, as a federal agency, the CNSC has adopted certain

key concepts in environmental protection from other federal statutes. Where applicable, the

CNSC expects licensees to apply the more-demanding meanings from federal legislation in the

scope of their EMS.

To avoid misinterpretation of these concepts, the licensee should review the following differences

between key concepts in federal legislation and those in CAN/CSA ISO 14001 (2004 edition or

successor editions) [1, 2] and consider them in the scope of their EMS:

the CNSC’s definitions of environment, environmental effect (i.e., impact) and pollution

prevention (i.e., prevention of pollution) in this regulatory document are taken from federal

legislation and are broader than the definitions of the related terms in CAN/CSA

ISO 14001 (2004 edition or successor editions) [1, 2]

in both the NSCA and the Canadian Environmental Protection Act, 1999 (CEPA 1999), risk

is a key concept in environmental protection that is not addressed in CAN/CSA

ISO 14001 [1, 2]

the licensee should use the ERA as one of the core sources to inform the significant

environmental aspects and effects of the EMS

CAN/CSA ISO 14001 [1, 2] provides only minimal guidance on the interpretation of adverse

environmental effects

Pollution prevention is the key principle underlying the management of hazardous substances in

Canada. Section 64 of CEPA 1999 defines the nature of toxic substances, explicitly defining

unreasonable risk for certain scheduled substances. For other potentially hazardous substances

that are not subject to legislation, unreasonable risk may be interpreted in terms of likely

significant adverse effects. This concept is nearly equivalent to the CAN/CSA ISO 14001 [1, 2]

concept of significant environmental effects. In the CNSC licensing process for Class I nuclear

facilities and uranium mines and mills, the process for an EPR under the NSCA or an impact

assessment under the Impact Assessment Act provides an initial framework for identifying and

Documents

Environmental Protection Environmental Principles, Assessments … · 2020. 10. 14. · September 2020 REGDOC-2.9.1, Environmental Principles, Assessments and Protection Measures